15 harassers are at the mercy of a hearer's sensitivities. Moreover, William has offered no meaningful evidence to show that the statute has a real and substantial deterrent on protected speech or that it actually denies fair notice of what conduct is proscribed. The required elements are clearly delineated such that § 43A (a) leaves no putative harassers wondering what is prohibited. Accordingly, William's facial challenge to § 43A (a) fails. 2. As-applied challenge. The defendants' as-applied constitutional challenge also fails because the conduct in question was not protected speech, but rather a hybrid of conduct and speech integral to the commission of a crime. Accordingly, § 43A (a), as applied to the defendants, does not implicate constitutionally protected speech rights. "[I]t has never been deemed an abridgment of freedom of speech or press to make a course of conduct illegal merely because the conduct was in part initiated, evidenced, or carried out by means of language, either spoken, written, or printed." United States v. Sayer, 748 F.3d 425, 433 (1st Cir. 2014), quoting Giboney v. Empire Storage & Ice Co., 336 U.S. 490, 502 (1949). The defendants do not claim that creating fictitious Internet postings and sending a letter falsely accusing someone of a crime constitute legal conduct. Their conduct served solely to harass the Lyonses by luring numerous strangers and

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